ISLAMABAD: Appellate Tribunal Inland Revenue, Islamabad has directed three leading State-Owned Enterprises (SOEs) to immediately approach Federal Board of Revenue (FBR) for the constitution of Alternative Dispute Resolution Committees (ADRCs) to resolve their tax related disputes. These appeals, involving fiscal disputes between various State-Owned Enterprises (SOEs) and the State, have been instituted before the ATIR before July 1, 2024. “For SOEs, participation in the ADRC mechanism is not an exercise in discretion but a statutory compulsion. The text of the law is couched in mandatory terms, leaving no interpretive ambiguity. An SOE is obligated to approach the FBR for the Constitution of an ADRC, and unlike its non-SOE counterpart, it does not possess the liberty to assess the desirability of this route. More importantly, the statute mandates that SOEs must withdraw all pending appellate proceedings prior to the initiation of ADRC proceedings, ATIR directed the SOEs. According to the order of the ATIR, the present appeals—being instituted by a state-owned enterprise — are no…